ML20137H003

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Ack Receipt of 780727 Response to Notice of Violation
ML20137H003
Person / Time
Site: Dow Chemical Company, 05000000
Issue date: 08/11/1978
From: Hind J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Langner R
DOW CHEMICAL CO.
Shared Package
ML20136D183 List: ... further results
References
FOIA-85-256, FOIA-85-258, FOIA-85-259, FOIA-85-261 NUDOCS 8508280051
Download: ML20137H003 (1)
v • d • e


Text

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AUG111978 Docket No. 50-264 -

Dow C 6 4c=1 Company

' ATTN: Dr.1. R. Langner Radiation Safety Committee 1803 Building Midland, MI 48640 Gentlemen:

We have reviewed your response dated July 27, 1978, to the Notice of Violation which was sent to you on July 12, 1978, and we have no further questions concerning these matters at this time.

We plan to continue to conduct unannounced inspections to as-certain whether corrective measures are implemented in accor-dance with your e-itments made to the Comission and to determine whether activities are performed in couplianem with the NRC requirements.

Sfacerely, l

J. A. Eind Chief Safeguards Branch ces James B. Banes Vice President and General Counsel ec w/itr dtd 7/27/78:

Central Files Reproduction Unit NRC 20b ec w/1tr dtd 7/27/78 w/o attachment (Part 2.790(d)):

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NRC Form 316A (RIK) (5-74) NRCM 02040 *U. 5. GOVERNMENT PRINTING OFFICE: 1978 -253-818

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Dr. R. R. Langner Radiation Safety Cosmaittee 1803 Building Midland, MI 48640 Gentlemen:

4 This refers to the inspection conducted by Mr. C. H. Brown of this office on July 25-27, 1978, of activities at the Dow TRIGA Reactor authorized by NRC Operating License No. R-108 and to the discussion of our findings with Mr. G. Kochammy and others of your staff at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas e===ined during the inspection. Within these areas, the inspection consisted of a selective ====i== tion of procedures and representative records, observations, and interviews with personnel.

No items of noncompliance with NRC requirements were identified during the course of this inspection.

In accordance with Section 2.790 of the NRC's " Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NEC's Public Document Room, except as follows. If this report

' contains information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this letter, to withhold such information from public disclosure. The application must include a full statement of the ressoas for which the informa, ion is con-sidered proprimeary, and should be prepared so that ' wprietary information identified in the application is contained in an 4 -- enclosure to the application.

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NRC Form 318A (R33E) (5-76) NRCM 02040 *U. S. GOVERNMENT PRINTING OFFICE: 1978-253-818

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t Dow Chemical U.S.A. AUG 151978 4 We will gladly discuss any questions you have concermias this

- - inspection.

Sincerely, Gaston Fiorelli, Chief Reactor Operations and Nuclear Support Branch

Enclosure:

IE Inspection Report No. 50-264/78-03 cc w/ encl:

Dr. O. V. Anders, Reactor Supervisor Central Files Reproduction Unit NRC 20b PDR NSIC TIC

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NRC Form 3188 (RIII)(178) NRCM O240 eu. s. GovtRNa#ENT PRIMTING OFFICE: 1978-253-017

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 50-264/78-03 License No. R-108 Docket No. 50-264 Licensee: Dow Chemical Midland, MI Facility Name: Dow TRIGA Research Reactor Facility Inspection at: Dow TRIGA Research Reactor Facility Inspection Conducted: July 25-27, 1978 Inspector: C. Bro ,

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Inspection Summary Inspection on July 25-27, 1978 (Report No. 50-264/78-03)

Areas Inspected: Routine, unannounced inspection was performed on logs and records, audits, requalification training, procedures, surveillance, experiments, and observation of reactor operations. The inspection involved 17 inspector-hours onsite by one NRC inspector.

Results: No items of noncompliance or deviations were identified.

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DETAILS

1. Persons Contacted
  • 0. V. Anders, Reactor Supervisor
  • G. L. Kochanny, Manager, Building 1602 T. J. Quinn, Reactor Operator
  • Denotes licensees attending the management interview.
2. Logs, Records and Organization A review was performed to verify that the facility logs and records were maintained consistently with regulatory requirements and that the organi-zation complied with the cutline in the Technical Specifications.

The organization was found to be consistent with the requirements and no major personnel changes had occurred. The control room manning was observed to meet the requirements. The log and record review indicated that no significant problems had occurred during the period under review. The requir.ed records were available. Specific comments are contained in the applicable sections. No items of noncompliance or deviations were iden-tified in this area.

3. Audits and Review The audit and review functions of the facility's staff and the Reactor
  • Operating Committee (ROC) were reviewed to verify the conformance with the Technical Specification requirements. The minutes of the Radiation Safety Committee (RSC) were also reviewed. The review of the records indicated that the audit and review functions were being performed within the Technical Specifications and procedural requirements. The licensee agreed to review the updating of the procedures so that the latest procedure could be verified in use by the operators and the audit teams more efficiently. The revisions and amendments (three changes) were noted to be kept with the Technical Specifications, but the changes were not noted in applicable sections and the licensee agreed to evaluate this item also. These items were discussed in the management interview.

No items of noncompliance or deviations were identified in this area.

4. Requalification Training The requalification training records were reviewed to verify that the requalification training was conducted as required. The records were found maintained as required for the examination and individual's tests including the documentation for the required reactor operations evalu-ation. The records contained lecture attendance and lecture guides. The lecture guides contained review of all the facility procedures. The changes in the facility and procedures review, if any, had been implemented into the training program. Sufficient time appears to be pro-vided in the areas covered by the program. The licensee is reviewing a minor item to verify correctness. No items of noncompliance or deviations were identified in this area.
5. Procedures The facility procedures were reviewed to verify that adequate control was provided for safety-related operations and that effective procedural con-trol had been implemented. The responsibilities of the operators are clearly established. The startup, shutdown, surveillance, and maintenance (maintenance procedures, in general, are the ones supplied by the reactor vendor) appear technically adequate and meet the Technical Specification requirements. The startup and shutdown of the reactor were observed and the procedures appeared adequate. No items of noncompliance or deviations were identified in this area.
6. Surveillance A review was made of the surveillance records and procedures to ascertain the adequacy of the program and verify that it was conducted within the requirements. The surveillance procedure appears to be technically adequate for verification of the required Technical Specifications items and was up-to-date. The surveillance records indicated all the surveillance items had been performed for the inspection period. The licensee's review of this area appeared to be satisfactory. No items of noncompliance or deviations were identified in this area.
7. Experiments The experimental records were reviewed to verify that the experiments were conducted in accordance with the stated requirements. The records indi-cated all experiments and irradiations were performed under approved conditions. No new experiments were approved during the inspection period.

The number of runs and the number of irradiations had increased slightly.

The sample of records reviewed were all for the same type sample of irra-diations. (Approval Number 22). The other approvals and reviews were per-formed. No items of noncompliance or deviations were identified in this area.

8. Management Interview A management interview was held with the licensee (as denoted in paragraph 1) at the conclusion of the inspection. The following items were included in the discussion:
a. The licensee agreed to consider noting revisions in the affected Technical Specification sections, supplementing maintaining the changes as additional sections of the Technical Specification volume (paragraph 3),
b. The licensee is considering dating all procedures with the approval date (paragraph 3).
c. The licensee agreed to review a minor item in the requalification program for correctness (paragraph 4).
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